ML20133C502
| ML20133C502 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/23/1985 |
| From: | Blake J, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133C487 | List: |
| References | |
| 50-424-85-40, 50-425-85-31, NUDOCS 8510070383 | |
| Download: ML20133C502 (12) | |
See also: IR 05000424/1985040
Text
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UNITED STATES
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D.
NUCLEAR REGULATORY COMMISSION
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REGION 18
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101 MARIETTA STREET N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.: 50-424/85-40 and 50-425/85-31
Licensee: Georgia Power Company
P. O. Box-4545
Atlanta, GA 30302
- Docket Nos.:
50-424 and 50-425
License Nos.: CPPR-108 and CPPR-109
Facility Name: Vogtle 1 and 2
Inspection Condu ed: August 19 - 23, 1985
T//G/8[
Inspector:
A r c4
w
G.
stro
Da e ' Signed
Approved by.
v
_
k 87 W
J.
lakT, Sectiori Chief
Date' Signed
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M er als and Processes Section
vi ion of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection involved 22 inspector-hours on site
in the areas of employee concerns, housekeeping (Units 1 and 2), material control
(Units 1 and 2), reactor coolant pressure boundary piping (Unit 1), safety-
related
ping (Unit 1), safety-related components, and licensee identified items
(50.55(e
.
Results:
Two violations were identified - Failure to Follow Procedures for
Control of Welding - paragraphs 7.b(1) and 7.b(3); and Failure to Protect Permanent
Plant Equipment - paragraph 9.
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REPORT DETAILS
1.
Licensee Employees Contacted
- W. T. Nickerson, Deputy Project General Manager
- G. Bockhold, General Manager, Vogtle Nuclear Operations Division
- C. W. Hayes, Vogtle Quality Assurance (QA) Manager
- E. D. Groover, QA Site Manager, Conrtruction
- C. E. Belflower, QA Site Manager, Operations
- D. M. Fiquett, Unit 2 Field Construction Manager
- W. Wagner, Quality Control (QC) Superintendent-0peration
- M. Bellamy, Initial Test Manager, Operations
- M. S. Hairston, Regulatory Compliance Associate Engineer
- G. A. McCarley, Project Compliance Coordinator
Other licensee employees contacted included construction craftsmen, engineers,
t ar' nicians, operators, mechanics, security force members, and office
p..
,rnnel.
Other Organizations
- D. L. Kinnsch, Project Field Engineer, Bechtel Power Company (BPC)
- J. Mamon, Quality Engineer, BPC
- G. H. Fredy, Technical Specialist, BPC
- J. Steele, " Manager, Pullman Power Products (PPP)
- T. C. Clark, Assistant QA Manager, PPP
- A. Holtz, V-SAMU Piping Systems As-Built Engineer, Westinghouse
- C. S. McCall, Construction Supervisor, Oglethorpe Power Company
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on August 23, 1985, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
(0 pen) Inspector Followup Item 424/85-40-01, 425/85-31-01 - Assurance of
Necessary Minimum Clearances for Installed Piping, paragraph 5.
(0 pen) Unresolved Item 424/85-40-02, 425/85-31-02 - Assurance of Adequate
Backpurge for Welding Stainless Steel Piping, paragraph 7.b.(1).
(0 pen) Violation 424/85-40-03, 425/85-31-03 - Failure to Follow Procedures
for Control of Welding, paragraphs 7.b (1) and 7.b.(3).
(0 pen) Violation 424/85-40-04 - Failure to Protect Permanent Plant Equip-
ment, paragraph 9.
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The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
detennine whether they are acceptable or may involve violations or devia-
tions.
One new unresolved item identified during this inspection is
discussed in paragraph 7.b.(1).
5.
Independent Inspection Effort
ilousekeeping (548348), Material Identification and Control (42902B) and
Miterial Control (429408)
The inspector conducted a general inspection of Units 1 and 2 containments
and the reactor auxiliary building to observe activities such as house-
keeping, material identification and control; material control, and storage.
During the above inspection the inspector noted apparent clearance problems
between installed piping and Unit 1 containment pipe racks. There appeared
to be potential for contact between the 12" x 12" x 6" Reducing Tee In
Reactor Coolant Line 1-k4-1201-036-01 and the top of Column 8 in rack R0001.
There also appeared to be potential for contact on other locations between
the racks and pipe clamps which will be used to attach snubbers and struts.
Final alignment of the clamps will reduce the present clearances in these
locations.
Cognizant licensee personnel informed the inspector that BPC was in process
of revising specification X4Z01, Division P3 to include minimum separation
distances between piping and other obstructions. A general minimum separa-
tion of 1" in the direction of the obstruction will be imposed and any
deviations will require evaluation and acceptance by the project engineer.
The inspector was also informed that these requirements are incorporated in
the latest revision of PPP procedure IX-3, which is nearing final approval.
Cognizant licensee personnel also informed the inspector that a Deviation
Report (DR) would be issued in response to inadequate separation at
Column 8 of Rack R0001 and that additional generic corrective actions will
be required to assure adequate implementation of the new general 1" minimum
separation criteria.
The inspector informed cognizant licensee personnel
that NRC concern on this matter will be identified as Inspector Followup
Item 424/85-40-01, 425/85-31-01 - Assurance of Necessary Minimum Clearances
for Installed Piping.
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6.
Employee Concerns
NRC had previously received an employee concern regarding inadequate
qualification of a PPP welder who was making heavy section weldments on
Unit 1 containment pipe racks.
The inspector reviewed pertinent qualifica-
tion data for the welder in question. The inadequate qualification had been
identified on February 16, 1984, and DR No. PP-4123 issued to accomplish
removal of weld metal to the thickness allowed and rewelding by another
welder qualified to unlimited thickness.
The original welder completed
additional testing to qualify for unlimited thickness welding on
February 23, 1984.
Af ter additional record review by PPP personnel, six
additional welds were identified as having been incorrectly complated by the
welder involved prior to February 23, 1984.
DR No. PP-11533 was issued to
accomplish adequate engineering disposition of the six welds involved.
The inspector had previously conducted final visual inspection and review of
necessary wcld inspection and welder qualification data for several similar
welds completed by the welder in question after February 23, 1984 (Inspec-
tion Report Nos. 424, 425/84-30 and 424, 425/85-03).
No deficiencies
related to welder performance or qualification were identified.
The inspector also examined revisions to PPP Procedures VI-5 " Control of
Process Sheets and Weld Rod Requisition" and VIII-3 " Control of Welding
Materials (Field)" which clarify requirements for check of required welder
qualification to the thickness involved during issuance of the weld metal
requisition form.
Cognizant licensee personnel informed the inspector that
a records review had not identified any other instances of inadequate
qualifications.
The inepvtor concluded that licensee actions had been sufficient to address
this e p jee concern and this matter is considered closed.
7.
Reactor Coolant Pressure Boundary Piping (Unit 1)
The inspector examined welding and nonwelding activities for reactor coolant
pressure boundary piping to determine whether applicable code and procedure
requirements were being met.
The applicable code for rector coolant
pressure boundary piping is the ASME Boiler and Pressure Vessel Code,
Section III,1977 Edition with Addenda through W77,
a.
Review of Nonwelding Quality Records (49055)
The inspector selected various reactor coolant piping components (e.g.,
pipe, fittings and welded-in components) for review of pertinent
records to determine conformance with procurement, storage and
installation specifications and QA/QC site procedures.
Records of the following items were selected for review to ascertain
whether they (records) were in conformance with applicable requirements
relative to the following areas: material test reports / certifications;
vendor supplied NDE reports; Nuclear Steam Service Supply quality
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releases; site receipt inspections; storage; installation; and vendor
nonconformance reports.
Item
Heat / Control No.
2" Sched. 160 pipe
466976
2' x 2" x 1" sched. 160 TEE
E7328
Within the areas inspected, no violations or deviations were
identified.
b.
Welding Activities
(1) Observation of Work (55173) (Unit 1)
The inspector observed in-process welding activities of reactor
coolant piping field welds inside of containment as described
below to determine whether applicable code and procedure require-
ments were being met.
The below listed repair welds were examined in-process to verify
work conducted in accordance with traveler, welder identification
and location, welding procedures, WPS assignment, welding
technique and sequence, materials identify, weld geometry, fit-up;
temporary attachments, gas purging,
preheat, electrical
characteristics, shielding gas, welding equipment condition,
interpass temperature, interpass cleaning, process control
systems, qualifications of inspection personnel, and weld history
records.
Size
Status
1K4-1201-027-01 R/6
193-W-109A*
2"
Fit-up & Tack
IX4DL4020 R/0
059-W-04-R1
6"
Fit-up & Tack
- Previous weld completely removed
During the above inspection the inspector informed cognizant
licensee personnel of the continuing NRC concern regarding the
assurance of adequate backpurge when completing stainless steel
welds. Observations concerning weld 193-W-109A are as follows:
Backpurge was more critical than normal since this was a
repair weld.
The first tack had been completed prior to the inspector's
arrival but no oxygen analyzer was present.
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The welder was uncertain of either the backpurge time
requirements or the 0.5% (or less) oxygen requirements for
adequate backpurge as incorporated in Section 4.0 of the PPP
General Welding Standard (GWS-III/I Rev. 3/28/84).
The technique sheet for the controlling welding procedure
specification (WPS No. 29-III/I-6-08-1) was not the latest
revision which includes clarification of the 0.5% (or less)
oxygen requirement.
After an oxygen analyzer had been secured, approximately 40
minutes were required to reach an acceptable 0.5% oxygen
limit due to inefficient placement of tape on the joint
involved.
The repair had been required due to root defects on the
original welds involved.
QC inspectors are not required to inspect for assurance of
adequate backpurge except on a random basis.
(The welder
involved could not remember any occasion during which he had
been so monitored.)
Due to the above observations, the inspector conducted a random
survey of several welders who normally weld stainless steel pipe.
Approximately half of the welders were uncertain of the specifics
regarding backpurge requirements.
Also, technique sheets for
other WPSs which had been issued from the "doublewide" welding
materials distribution center (WMDC) were not the latest revisions
which include clarification on backpurge requirements.
The
inspector noted that failure to distribute the latest technique
sheets was a lack of conformance to paragraph 1.4 of the PPP
General Welding Standard (GWS.III/I) 12/14/84 revision.
This is
another example of violation 424/85-40-03, 425/85-31-03 and is
further reported in paragraph 7.b.(3).
The inspector also noted
that NRC concern regarding adequate backpurge had been discussed
with cognizant licensee personnel during previous inspections wit'
special emphasis given to the need for transmitting clarified
infonnation on backpurge to the welders involved.
The inspector
further noted that code Class 3 welds do not receive
nondestructive root examination and therefore adequate backpurge
's the major assurance against unidentified root defects.
The
inspector informed cognizant licensee personnel that NRC's concern
regarding this matter will be identified as Unresolved Item
424/85-40-02, 425/85-31-02 - Assurance of Adequate Backpurge for
Welding Stainless Steel Piping.
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(2) WelderQualification(55177)
The inspector reviewed the PPP program for qualification of
welders and welding operators for compliance with QA procedures
and ASME Code requirements.
The following welder qualification status records and " Records of
Performance Qualification Test" were reviewed relative to the weld
joints-listed in paragraph 7.b(1) and 8.b(1).
Welder Symbol
WPS.
CW-1
29-III/I-8-08-1
DA-1
38-III/I-8-KI-1
DV-1
27-III/I-8-08-12
GF-1
32-III/I-8-12
(3) Welding Filler Material Control (55172)
The inspector reviewed the PPP program for control of welding
materials to determine whether materials were being purchased,
accepted, stored and handled in accordance with QA procedures and
applicable c'de requirements.
The following specific areas were
examined.
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Purchasing, receiving, storing, and distribution and handling
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procedures; material identification; and inspection of
welding material issuing stations.
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Welding material purchasing and receiving records for the
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following material applicable to the weld joints listed in
paragraphs 7.b.(1) and 8.b.(1) were reviewed for conformance
with applicable procedures and code requirements.
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bge
Size.
Heat, Lot, Batch /No.
1/16" x 36"
26245
3/32" x 36"
05394
1/8" x 36"
05394
During the above inspection the inspector observed apparent
inconsistencies in the oven check daily log for the doublewide
WMOC.
On August 20, 1985, the inspector observed that stationary
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holding ovens nos. 20, 25, and 26 were turned off, were at ambient
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temperature, and that all electrodes had been removed.
However,
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the daily log for August 20, listed 300*F, 300*F, and 260'F,
respectively, for these ovens.
Second shift WMDC personnel were
unable to explain the apparent discrepancy and stated that the log
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was the responsibility of first shift personnel.
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' The inspector responded that paragraph 7.2.1.G of PPP procedure
VIII-3 " Control 'of Welding Materials (Field)" required that
stationary oven holding temperature indicators be read daily to
verify that holding oven temperatures were between 250*F and
-400 F..
The intent is to assure that electrodes stored in ovens
are not issued if oven temperatures are less than 250 F and that
. the actual oven temperature was to be listed for the oven
involved.
On August 21, 1985,- temperatures of 300 F, 300 F and 285 F were
logged for oven nos. 20, 25, and 28.
After investigation,
cognizant licensee personnel informed the inspector that the ovens
had been turned off the morning of August 20, 1985, and sufficient
time had. elapsed for them to cool to ambient prior to the
inspector's initial observations.
The August 21, 1985, entrees
had been made without an actual observation of the oven
' temperature gages.
The inspector informed the licensee that this
matter and the failure to distribute proper welding technique
sheets reported in paragraph 7.b.(1) were considered a lack of
conformance to 10 CFR 50, Appendix B, Criterion V as implemented
by PPP Procedures VIII-3 and GWS III/I.
These matters will be
identified as Violation 424/85-40-03, 425/85-31-03 - Failure to
Follow Procedures for Control of Welding.
The inspector also
noted that the failure to follow procedure VIII-3 was considered a
repeat of violation 424, 425/85-14-02 for which corrective action
had been reported as completed by June 30, 1985.
Within ' the areas inspected, one violation, as noted above, was
identified. No deviations were identified.
8.
Safety-Related Piping (Unit 1)
The inspector examined welding and nonwelding activities for safety-related
piping to detennine whether applicable code and procedure requirements were
being met. The' applicable code for safety-related piping is the ASME Boiler
and Pressure Vessel Code,Section III,1977 Edition with Addenda through
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W77.
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a.
Review of Nonwelding Quality Records (49065)
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The inspector selected various safety-related piping components
(e.g., pipe, fittings and welded-in components) for review of pertinent
records to determine conformance with procurement, storage and
installation specifications and QA/QC site procedures.
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- Records of the following items were selected for review to ascertain
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~ hether they (records) were in conformance with applicable requirements
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relative to the following areas: material test reports / certifications;
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vendor supplied NDE reports; Nuclear Steam Service Supply quality
release; site receipt inspections; storage; installation; vendor
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nonconformance reports.
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Item
Heat / Control No.
System
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3/4" 1500# Sched. 160
ABOC
Chemical Volume and
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Control System (CVCS)
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3/4" Sched. 160 pipe
464057
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Within the areas inspected, no violations or deviations were
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identified.
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b.
Welding Activities
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(1) Observation of Work (55183) (Unit 1)
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The inspector observed in-process welding activities of safety
injection piping field welds inside of containment as described
below to determine whether applicable code and procedure require-
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ments were being met.
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The below listed welds are examined in-process to verify work
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conducted in accordance with traveler, welder identification and
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location, welding procedures, WPS assignment, welding technique
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and sequence, materials identity, weld geometry, fit-up; temporary
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attachments, gas purging, preheat, electrical characteristics,
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shielding gas, welding equipment condition, interpass temperature,
interpass cleaning, process control systems, qualifications of
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inspection personnel, and weld history records.
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Size
Status
$
1K4-1208-043-02 R/9
374-W-101
3/4"
ist. Pass
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1K4-1208-020-02 R/6
020-W-145A
3/4"
Fit-up
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The following inspector qualification status records and QA/QC
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Inspector Qualification / Certification records were reviewed
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relative to inspection of the weld joints listed above.
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Inspector
Type of Certification
PEM-PPP
VT-II
(2) Welder Qualification (551878)(Unit 1)
The inspector reviewed PPP's program for qualification of welders.
The applicable procedure is II-8, Welder Performance Procedure:
(12/14/84).
The following specific areas were examined:
Procedures for qualification of welders
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Procedures for maintaining continuity of status records
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Review of welder qualification status records and Records of
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performance Qualification Tests, relative to the weld joints
listed in' paragraph 8.b.(1) above is documented in paragraph
7.b.(2).
(3) Welding Material Control (551828)(Units 1 and 2)
The welding material control inspection documented in paragraph
7.b(3) for reactor coolant piping also applies to safety-related
piping.
Within the -areas inspected, one violation, as reported in
paragraph 7.b.(3),wasidentified. No deviations were identified.
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Safety-Related Components Observation of Work (50073)
The inspector examined Train A nuclear service cooling water pumps (P4-001,
P4-003, and P4-005) to determine whether:
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Installation requirements were met such as:
proper location, place-
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ment, orientation, alignment, mounting (torquing of bolts and expansion
anchors), flow direction, tolerances, and expansion clearances.
Precautions were taken to prevent damage during placement / mounting.
. Installation and inspection records were prepared and maintained.
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Maintenance inspection activities : including scope and frequency are
being performed according to instructions.
Protection is being provided in accordance with manufacturer's instruc-
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tions and/or established procedures as required, including protection
-against adverse temperature, humidity, flooding, and foreign mater:als
such as dirt, dust, bottles, cans, and general debris.
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Lubrication, rotation, and electrical resistance checks are being
performed as required.
Records are being maintained as to the status of installed components.
Appropriate stamps, tags, markings, etc. are in use to prevent over-
sight of required inspections, completion of tests, acceptance, and the
prevention of inadvertent operation.
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During the above inspection the inspector observed that pump motor heaters
were not energized and that pump motor internals were at ambient tempera-
.ture.
Cognizant licensee personnel informed the inspector that adequate
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protection of pump motor coil windings required that heaters be continuously
energized when the pump motor was not running.
Also, that the permanent
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electrical connections to the motors had been completed with exception of
the heaters which had been fed from a temporary circuit.
The inspector
observed that the temporary circuit involved appeared to have caused
interference with installation of hanger VI-1202-033-H004.
Associated
quality data for the hanger indicated Quality Control (QC) inspection of the
NF code welds on July 16, 1985, and final inspection of the hanger
installation on August 14, 1985.
Therefore, indications were that the
heaters had been de-energized for approximately one month.
Cognizant licensee personnel provided the inspector with copies of plant
maintenance work orders (PM0s) nos.18503926 (pump P4-001),18503952 (pump
P4-005) and 18503914 (pump P4-003), and stated that these PM0s were the
record for the last maintenance checks completed.
PM0 no. 18503926 was
initiated on July 9,1985, and actual maintenance work completed on July 21,
1985.
Final QC close-out approval occurred on August 9,1985.
PM0 nos.
1803952 and 18503914 were initiated on June 24, 1985, and actual maintenance
work completed on July 21, 1985.
Final QC close-out approval occurred on
August 13, 1985.
The preoperational maintenance cards for all PM0s
indicated that the check for heater energization was not applicable.
The
inspector noted that this check had been required on the equipment
maintenance storage list (EMSL) cards used during construction and that the
requirement originated from guidance in General Electric (GE) manual
GEH-3292C (page 3) that "the temperature of the windings should always be
maintained a few degrees above the temperature of the surrounding air."
Also, that Georgia Puwer Company (GPC) Nuclear Operations Procedure No.
20015-C, Rev. 2,
required in paragraph 4.5.2 that "preoperational
maintenance will be consistent with preventive and storage maintenance
identified and performed by construction personnel."
Further, that Section 4.5.3 allows the nuclear operations test supervisor to
delete or add requirements provided a preoperational change request card was
prepared and approved by the respective maintenance supervisor in accordance
with Section 3.6.b.
Neither the required preoperational change request
cards nor explanatiori of the deviation from EMSL criteria were provided to
the inspector during this inspection.
Subsequent to the inspection, the inspector received copies of preoperational
maintenance cards for PM0's Nos. 18504636 (pump P4-001), 18506356 (pump P4-005),
and 18506730 (pump P4-003) for maintenance work completed on August 12-13, 1985.
Requirements were that pump motor heaters be energized or that heat trace tape
be installed and energized.
Notes indicate that the test supervisor was
informed that pump motor heaters were not energized on August 12 and
August 13, 1985.
However, no heat trace tape was installed and heater
energization had not occurred by August 22, 1985.
The above clearly establishes that preventative maintenance inspection
procedures were inadequate to prevent damage or deterioration of equipment.
Failure to establish adequate measures to control storage and preservation
of equipment in accordance with work and inspection instructions to prevent
damage or deterioration is in violation of 10 CFR 50, Appendix B, Criterion 13.
This matter is identified as violation 424/85-40-04.
Failure to protect
permanent plant equipment.
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10. Licensee Identified Items (92700)
Prior to the inspection, the licensee identified the following items under
(Closed) Item 424/CDR 84-66, Containment Pipe-Rack Welds
On July 20, 1984, the licensee notified Region II of a 50.55(e) item
involving cracks in Unit 1 containment pipe-rack welds.
The final report
was submitted on October 17, 1984.
The proposed corrective action plan (DER-061) was reviewed during previous
inspections and concerns documented in Inspection Reports 424/84-30,
424/84-36, and 424/85-03.
Resolution of those concerns were documented in Inspection Report
424/85-08.
However this item has remained open pending additional assess-
ment of DER-061.
The inspector conducted additional discussions with licensee representa-
tives, reviewed supporting documentation, and observed representative
samples of work completed to DER-061.
The majority of work necessary to
accomplish corrective action has been completed.
Remaining inspection and
welding activities scheduled for completion under DER-061 provide assurance
that all NRC concerns have been adequately addressed.
This item is
considered closed.
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